Glenn
I have reviewed everything you have written on this subject and regret I do not have any simple solutions.
I do not believe you will get anywhere by challenging the "airy-fairy" language about process, it is so easily interpreted by CASA, they will also continue to defend their employees becuase they are vicariously liable for what is done in the name of CASA. The time for challenging the legal documents, such as what are now called safety findings or observations, seems also to have passed. My impression is that you were ground down because you tried to do the right thing instead of simply trading on until CASA came up with substantive action such as a safety alert or safety finding with which you could challenge or comply. They seem only to have disallowed a change to your operations manual, which, given that you had traded safely under the un-amended manual, only meant that you should trade on under the approved version. (Forgive me if I have misinterpreted).
I note that APTA is still trading and I assume that this is the entity you sold <https://www.auspta.edu.au/>. They claim to have approval to operate out of Latrobe and Ballarat, is this not what you were trying to do? Presumably this is the same AOC and they used your exposition? If this is so how can they justify the action taken against you?
Regardless, you now seem to be in a position of having lost everything because of the actions of a Government entity which is a body corporate and can therefore be sued. This entity will never agree to compensate you without being ordered to by the Federal Court, and even then they will claim that their action was at the time motivated only by their safety charter. Can I suggest that you run your case past a law firm that specialises in "no win/no-pay" cases and see if they think you have chance? If you have already done this then a believe you have run out of options short of talking to Senator Susan MacDonald (LNP - Queensland) who wants to lead a Senate investigation into CASA. This will not get you any money but might elecit some satisfaction.